SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

(in accordance with 40 CFR Part 51 - App. V)

SIP Submitted by: West Virginia Department of Environmental Protection

Date Submitted: December 6, 2012

Subject: Redesignation Requests and Maintenance Plans for the Charleston, West Virginia Nonattainment Area, With 

Respect to the 1997 and 2006 Fine Particulate Matter (PM2.5) National Ambient Air Quality Standards 

(NAAQS)

Completeness Review 

Completed by: Rose Quinto

Date Completed: February 4, 2013

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal letter of submittal from the Governor or his 

designee, requesting EPA approval of the plan or revision 

thereof.

1. Submittal letter dated December 6, 2012 from West Virginia 

Department of Environmental Protection Secretary Randy C. 

Huffman, to Shawn M. Garvin, Regional Administrator, EPA 

Region 3.

X

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, consent 

agreement in final form. That evidence shall include the date 

of adoption or final issuance as well as the effective date of the 

plan, if different from the adoption/issuance date.

2. Not applicable. Not a regulatory change - the submittal are

requests for redesignation and maintenance plans for the 1997 

and 2006 PM2.5 NAAQS, and for the 2006 PM2.5 NAAQS base 

year emissions inventory approval. 

X

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. The plan states that it has the necessary legal authority and 

necessary resources to enforce its rules or permit provisions on 

which the plan is based. 

X
2

4. A copy of actual regulation, or document submitted for 

approval and incorporation by reference into the plan, including 

indication of the changes made to the existing approved plan, 

where applicable. The submittal shall be a copy of the official 

State regulation/document signed, stamped, dated by the 

appropriate State official indicating that it is fully enforceable 

by the State. The effective date of the regulation/document 

shall, whenever possible, be indicated in the document itself.

4. Not applicable, see 2 above. X

5. Evidence that the State followed all of the procedural 

requirements of the State's laws and constitution in conducting 

and completing the adoption/issuance of the plan.

5. The submittal included documentation showing that the 

State followed State procedural and administrative 

requirements in issuing the plan.

X

6. Evidence that public notice was given of the proposed 

change consistent with procedures approved by EPA, including 

the date of publication of such notice.

6. A notice of public hearing and a public comment period was 

published in the Charleston Gazette and the West Virginia 

Register, both dated October 26, 2012. 

X

7. Certification that public hearings were held in accordance 

with the information provided in the public notice and the 

State's laws and constitution, if applicable.

7. A transcript of the public hearing showed the public hearing 

was held in accordance with the public notice. The December 

6, 2012 submittal letter certifies that the public hearing required 

by 40 CFR 51.102 was held in accordance with state laws and 

the requirements of 40 CFR 51.102(d).

X

8. Compilation of public comments and the State's response 

thereto.

8. The submittal included a compilation of comments received 

and the responses to the comments. 

X
3

Technical Materials

EPA REQUIREMENT STATE SUBMITTAL 

1. Identification of all regulated pollutants affected by the plan. 1. Chapter 1 of the Redesignation Request and Maintenance 

Plan show that NOx, SO2 and PM2.5 are the pollutants affected 

by the plan. 

 X

2. Identification of the locations of affected sources including 

the EPA attainment/nonattainment designation of the locations 

and the status of the attainment plan for the affected area(s).

2. Kanawha and Putnam Counties in West Virginia. X

 

3. Quantification of the changes in plan allowable emissions 

from the affected sources; estimates of changes in current 

actual emissions from affected sources or, where appropriate, 

quantification of changes in actual emissions from affected 

sources through calculations of the differences between certain 

baseline levels and allowable emissions anticipated as a result 

of the revision.

3. Detailed information on the point, area, nonroad and mobile 

source emissions estimates used in the requests for

redesignation and the maintenance plans for the 1997 and 

2006 PM2.5 NAAQS, and the 2006 PM2.5 NAAQS base year 

emissions inventory for the Charleston Area are provided in 

the submittal. 

X

4. The State's demonstration that the national ambient air 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved 

and implemented. 

4. West Virginia has developed a base year (2005) and 

projected (2018 and 2025) emissions inventories showing 

continued attainment of the PM2.5 NAAQS during the plan 

period. 

 X

5. Modeling information required to support the proposed 

revision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, 

justification for use of offsite data (where used), modes of 

models used, assumptions, and other information relevant to 

the determination of adequacy of the modeling analysis.

5. Not applicable. X
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6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Not applicable. X

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. Based on permanent and enforceable measures, West 

Virginia has projected emissions inventories for interim year 

2018 and out year 2025 to demonstrate maintenance 

throughout the entire 10-year period. 

 X

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Identified contingency measures will be implemented if the 

Area violates or exceeds the PM2.5 standard. These measures 

are intended to bring the area back to attainment of the

standard.

 X

9. Special economic and technological justifications required 

by any applicable EPA policies. (If a policy is not appropriate, 

explain why.)

9. Not applicable. 

10. A Section 107 request must be accompanied by a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.

10. Maintenance Plans for both 1997 and 2006 PM2.5 NAAQS 

were submitted to EPA Region III on December 6, 2012. 

These plans demonstrate maintenance for 2018 through 2025. 

 

 X